The U.S. Supreme Court issued a ruling declaring that mandatory life sentences for juvenile offenders is unconstitutional under the Eighth Amendment of the United States Constitution. You may read the full opinion here: Miller v. Alabama.
The Court reasoned that punishment for a crime should be proportionate to both the crime and the individual offender. The Court held that mandatory life sentences without possibility of parole for a juvenile essentially prohibits a court from considering the offender’s age, maturity level and characteristics of the crime committed. The court further reasoned that a mandatory life sentence disregards the possibility of rehabilitation. The concurring opinion added that resent studies in psychology and science continue to show that there are fundamental differences between juvenile and adult minds, making a child’s actions less likely to be the product of an irretrievably depraved character than the actions of an adult.
The Court is not prohibiting a court from imposing a life sentence without parole on juvenile offenders. However, the Court is prohibiting this as a mandatory sentence, reasoning that a court should have the opportunity to review mitigating factors and circumstances with regard to the juvenile before ordering life in prison.
Juvenile offenders who are currently serving mandatory sentences will now have the opportunity to have their sentence reconsidered. Pennsylvania’s state legislature is currently examining this court decision to determine what legislation needs to be drafted so that the Commonwealth is in compliance with the Constitution. To read more about the impact of this decision on the Commonwealth, you may access a Patriot News article here: PennLive.
This decision follows a trend in which the Supreme Court has been recognizing that juveniles should be given the opportunity to rehabilitate. In 2005 the court eliminated the death penalty for juveniles. In 2010 the court eliminated mandatory life sentence for juveniles convicted of any crime other than one involving a killing. The court reasoned, based off of those two prior decisions, that “the distinctive attributes of youth, diminish the penological justifications for imposing the harshest sentences on juvenile offenders, even when they commit terrible crimes.”
Another possible issue that could come up is how this decision will affect the new Megan’s Law requirements for Pennsylvania, which mandate that juvenile offenders register for life. Adults who commit crimes that fall within Megan’s Law are put into a tier system. Some must register for only 15 or 25 years and others for life. However, there is no tier system for juveniles. They must register for life. To read more about this tier system and Megan’s Law Updates, you can access our blog here: Megan’s Law Update.
The Supreme Court, in this decision, essentially holds that it is unconstitutional to prohibit a sentencing court from considering a child’s age, maturity level, circumstances of the crime, and other mitigating factors before imposing the harshest penalties on juvenile offenders. Registering for life is the harshest penalty under Megan’s Law, and as the legislation is drafted now, juvenile offenders must register for life, regardless of any mitigating factors. This would seem contrary to this most recent Supreme Court decision.